Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition:
Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause:
Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements.
Effect or Potential Effect:
The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs:
None.
Context:
Two instances of excess cash that were not eliminated within the allowable time frame were identified for the Federal Work-Study Program for the year ended June 30, 2024.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-004.
Recommendation:
We recommend the University continue to enhance its internal controls, policies and procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to ED.
Views of Responsible Officials:
A statement of procedure and workflow will be implemented to formally reconcile FWS - Title IV expenses to the general ledger on a monthly basis to ensure timely draws and adjustments. Adjustments and updates to the FISAP including prior year adjustments will be included in the Title IV reconciliation process and communicated immediately. The reconciliations will require two-tier approvals.
Federal Program Information: Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day.
Condition: Certain time records were prematurely approved by the students’ supervisors prior to the performance of the work by the students being completed. In addition, an instance was identified in which a student was not paid at least once per month as required.
Cause: Insufficiently designed internal controls and administrative oversight with respect to FWS disbursements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements.
Questioned Costs: None.
Context:
• For 4 of 40 Federal Work-Study (“FWS”) payments tested, the University reviewed and approved students’ timesheets before time was incurred.
• For 1 of 40 FWS payments tested, the student was not paid within the required timeframe.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-008.
Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that student timesheets are appropriately reviewed.
Views of Responsible Officials: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well.
The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program.
One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring.
The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Pell Grant Program (ALN: 84.063); Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 2 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 13 of 40 program level records tested, the University did not accurately report one or more program enrollment data elements.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2024 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-003.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. 1 of the 2 findings where the University did not certify the students’ enrollment data within 60 days was due to volume at NSC and deemed out of institutional control. Based on email correspondence with the Compliance Team at the National Student Clearinghouse, it was determined,
“For the delay between DV file being submitted by Howard University to NSC 08.27.2024 and processed by NSC 09.16.2024, I assess this was due to volume on NSC side at the time and outside institution control.”
The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP).
Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future.
Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Pell Grant Program (ALN: 84.063); Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 2 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 13 of 40 program level records tested, the University did not accurately report one or more program enrollment data elements.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2024 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-003.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. 1 of the 2 findings where the University did not certify the students’ enrollment data within 60 days was due to volume at NSC and deemed out of institutional control. Based on email correspondence with the Compliance Team at the National Student Clearinghouse, it was determined,
“For the delay between DV file being submitted by Howard University to NSC 08.27.2024 and processed by NSC 09.16.2024, I assess this was due to volume on NSC side at the time and outside institution control.”
The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP).
Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future.
Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition:
Certain loan disbursement notifications were not sent timely.
Cause:
Insufficient internal controls and administrative oversight with respect to loan disbursement notifications.
Effect or Potential Effect:
The University is not in compliance with loan disbursement notification requirements.
Questioned Costs:
None.
Context:
For 16 of 40 loan disbursements selected for testing, the notification was not sent to the borrower within the required timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe.
Views of Responsible Officials:
Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports.
Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file.
Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients with fiscal year ends of June 30, 2023 to submit Single Audit reports to the Federal Audit Clearinghouse within the required time frame.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
In addition, the University did not submit the June 30, 2023 Single Audit to the Federal Audit Clearinghouse by the required deadline.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Submission of the University’s fiscal year 2023 Single Audit was delayed due to the resulting investigation.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year. The related investigation also resulted in the University not submitting its 2023 Single Audit to the Federal Audit Clearinghouse within the required timeframe.
Questioned Costs:
$196,258
Context:
As discussed in Finding 2024-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2024 that identified both the suspected misappropriation and the related questioned costs.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-002.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
Accounts Payable (AP) will create a Corrective Action plan to include the following.
1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients with fiscal year ends of June 30, 2023 to submit Single Audit reports to the Federal Audit Clearinghouse within the required time frame.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
In addition, the University did not submit the June 30, 2023 Single Audit to the Federal Audit Clearinghouse by the required deadline.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Submission of the University’s fiscal year 2023 Single Audit was delayed due to the resulting investigation.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year. The related investigation also resulted in the University not submitting its 2023 Single Audit to the Federal Audit Clearinghouse within the required timeframe.
Questioned Costs:
$196,258
Context:
As discussed in Finding 2024-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2024 that identified both the suspected misappropriation and the related questioned costs.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-002.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
Accounts Payable (AP) will create a Corrective Action plan to include the following.
1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients with fiscal year ends of June 30, 2023 to submit Single Audit reports to the Federal Audit Clearinghouse within the required time frame.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
In addition, the University did not submit the June 30, 2023 Single Audit to the Federal Audit Clearinghouse by the required deadline.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Submission of the University’s fiscal year 2023 Single Audit was delayed due to the resulting investigation.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year. The related investigation also resulted in the University not submitting its 2023 Single Audit to the Federal Audit Clearinghouse within the required timeframe.
Questioned Costs:
$196,258
Context:
As discussed in Finding 2024-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2024 that identified both the suspected misappropriation and the related questioned costs.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-002.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
Accounts Payable (AP) will create a Corrective Action plan to include the following.
1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
G. Matching - According to the grant agreement, a non-federal match of not less than 50% of the Federal funds paid by the grantor to the grant recipient under this grant is required as a condition of the grant.
Condition:
The University was unable to provide documentation showing that its cost share requirement had been met.
Cause:
Insufficient internal controls and administrative oversight with respect to cost share/matching requirements.
Effect or Potential Effect:
The University was not in compliance with the mandated matching requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation supporting that its cost share requirement had been met for the program.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and procedures to ensure that matching funds are appropriately tracked.
Views of Responsible Officials:
Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
G. Matching - According to the grant agreement, a non-federal match of not less than 50% of the Federal funds paid by the grantor to the grant recipient under this grant is required as a condition of the grant.
Condition:
The University was unable to provide documentation showing that its cost share requirement had been met.
Cause:
Insufficient internal controls and administrative oversight with respect to cost share/matching requirements.
Effect or Potential Effect:
The University was not in compliance with the mandated matching requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation supporting that its cost share requirement had been met for the program.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and procedures to ensure that matching funds are appropriately tracked.
Views of Responsible Officials:
Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
G. Matching - According to the grant agreement, a non-federal match of not less than 50% of the Federal funds paid by the grantor to the grant recipient under this grant is required as a condition of the grant.
Condition:
The University was unable to provide documentation showing that its cost share requirement had been met.
Cause:
Insufficient internal controls and administrative oversight with respect to cost share/matching requirements.
Effect or Potential Effect:
The University was not in compliance with the mandated matching requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation supporting that its cost share requirement had been met for the program.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and procedures to ensure that matching funds are appropriately tracked.
Views of Responsible Officials:
Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
C. Cash Management - Institutions are permitted to draw down Title IV funds prior to disbursing funds to eligible students and parents. The institution’s request must not exceed the amount immediately needed to disburse funds to students or parents. A disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either student financial aid funds or institutional funds. The institution must make the disbursements as soon as administratively feasible, but no later than 3 business days following the receipt of funds. Any amounts not disbursed by the end of the third business day are considered to be excess cash and generally are required to be promptly returned to the U.S. Department of Education (the “ED”) (34 CFR section 668.166(a)(1)). Excess cash includes any funds received from the ED that are deposited or transferred to the institution’s Federal account as a result of an award adjustment, cancellation, or recovery. However, an excess cash balance tolerance is allowed if that balance: (1) is less than one percent of its prior-year drawdowns; and (2) is eliminated within the next 7 calendar days (34 CFR sections 668.166(a) and (b)).
Condition:
Certain instances during the year were identified in which Title IV funds drawn were held in excess of the allowable time frame.
Cause:
Insufficient internal controls and administrative oversight with respect to Cash Management compliance requirements.
Effect or Potential Effect:
The University is not in compliance with Cash Management compliance requirements. While amounts were within allowable thresholds, certain funds were overdrawn and held in excess of the allowable time frame.
Questioned Costs:
None.
Context:
Two instances of excess cash that were not eliminated within the allowable time frame were identified for the Federal Work-Study Program for the year ended June 30, 2024.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-004.
Recommendation:
We recommend the University continue to enhance its internal controls, policies and procedures to ensure that an account review occurs no later than the third business date after a federal draw to determine whether amounts were appropriately disbursed in accordance with federal regulations or require a return to ED.
Views of Responsible Officials:
A statement of procedure and workflow will be implemented to formally reconcile FWS - Title IV expenses to the general ledger on a monthly basis to ensure timely draws and adjustments. Adjustments and updates to the FISAP including prior year adjustments will be included in the Title IV reconciliation process and communicated immediately. The reconciliations will require two-tier approvals.
Federal Program Information: Federal Work-Study Program (ALN: 84.033)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): N. Special Test and Provisions – Disbursements to or on Behalf of Students – General Disbursement Criteria – Federal Work-Study Program – In accordance with 34 CFR 675.19(b)(2)(i), the institution must establish and maintain fiscal records that include a certification by the student’s supervisor, an official of the institution or off-campus agency, that each student has worked and earned the amount being paid. The certification must include or be supported by, for students paid on an hourly basis, a time record showing the hours each student worked in clock time sequence, or the total hours worked per day.
Condition: Certain time records were prematurely approved by the students’ supervisors prior to the performance of the work by the students being completed. In addition, an instance was identified in which a student was not paid at least once per month as required.
Cause: Insufficiently designed internal controls and administrative oversight with respect to FWS disbursements.
Effect or Potential Effect: Federal awards were not disbursed in accordance with federal regulations, and the University was not in compliance with recordkeeping requirements.
Questioned Costs: None.
Context:
• For 4 of 40 Federal Work-Study (“FWS”) payments tested, the University reviewed and approved students’ timesheets before time was incurred.
• For 1 of 40 FWS payments tested, the student was not paid within the required timeframe.
Identification as a Repeat Finding: This is a repeat of prior year Finding 2023-008.
Recommendation: We recommend the University enhance its internal controls, policies and procedures to ensure that student timesheets are appropriately reviewed.
Views of Responsible Officials: Federal Work Study (FWS) supervisors are required to have training on the appropriate policies and procedures when hiring a FWS student. They sign off on the Federal Work Study supervisor agreement stating they understand they must follow these procedures and losing the privilege of hiring FWS students can be the result of not following these policies and procedures. One of these policies is that students cannot have time approved prior to working those hours, as this is a not a best practice. The Center for Career & Professional Success began using this updated FWS supervisor agreement beginning with the Spring 2025 semester. All FWS supervisors who had students for Fall 2024 were required to review and sign the updated agreement as well.
The Federal Work Study Coordinator (located in the Center for Career & Professional Services) is responsible for reviewing the hours a student works. The Federal Work Study Coordinator also ensures supervisors have approved the correct number of hours and the hours were approved after the student worked those hours. The full-time Federal Work Study Coordinator position was filled prior to the end of the Fall 2024 semester, and this ensures a full-time employee is now in place to help provide a more active review of the Federal Work Study program.
One student was not paid FWS earnings within 30 days. At the time, Howard University did not print out paper checks, only providing FWS payments as a direct deposit. The student was to be paid for those two pay periods (10/8/23-10/21/23 and 10/22/23-11/4/23) on 11/3/23 and 11/17/23. The student did not have any payment selections set up in the system for the earnings to be deposited into and this delayed the receipt of the Federal Work Study payment. Working with the AVP for Enrollment Management, we have discussed with Payroll the need to process a paper check if a student chooses this delivery method. The University is also working on an awareness campaign that will encourage students to set up their direct deposit information in Workday. Students understanding the need to set up direct deposit and the willingness to process paper checks, if necessary, should prevent this finding from recurring.
The Associate Director for Compliance or designee will review when the supervisor approved the students’ hours as a part of the bi-semester Federal Work Study sample. These reviews are completed to ensure students are paid on-time and accurately, as well as ensure the student is not working during class hours. These reviews of FWS hours matching the students’ earnings will provide another layer of oversight.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Pell Grant Program (ALN: 84.063); Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 2 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 13 of 40 program level records tested, the University did not accurately report one or more program enrollment data elements.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2024 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-003.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. 1 of the 2 findings where the University did not certify the students’ enrollment data within 60 days was due to volume at NSC and deemed out of institutional control. Based on email correspondence with the Compliance Team at the National Student Clearinghouse, it was determined,
“For the delay between DV file being submitted by Howard University to NSC 08.27.2024 and processed by NSC 09.16.2024, I assess this was due to volume on NSC side at the time and outside institution control.”
The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP).
Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future.
Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Pell Grant Program (ALN: 84.063); Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Enrollment Reporting – Institutions are required to report enrollment information under the Pell grant and the Direct and Federal Family Education Loan (“FFEL”) loan programs via the National Student Loan Data System (“NSLDS”) (OMB No. 1845-0035), although FFEL loans are no longer made or a part of the Student Financial Assistance Cluster, a student may have a FFEL loan from previous years that would require enrollment reporting for that student (Pell, 34 CFR 690.83(b)(2); FFEL, 34 CFR 682.610; Direct Loan, 34 CFR 685.309). The administration of the Title IV programs depends heavily on the accuracy and timeliness of the enrollment information reported by institutions. Institutions must review, update, and verify student enrollment statuses, program information, and effective dates that appear on the Enrollment Reporting Roster file or on the Enrollment Maintenance page of the NSLDS Professional Access (“NSLDSFAP”) website which the financial aid administrator can access for the auditor. The data on the institution’s Enrollment Reporting Roster, or Enrollment Maintenance page, is what NSLDS has as the most recently certified enrollment information. There are two categories of enrollment information, “Campus Level” and “Program Level,” both of which need to be reported accurately and have separate record types. The NSLDS Enrollment Reporting Guide provides the requirements and guidance for reporting enrollment details using the NSLDS Enrollment Reporting Process.
Campus Level: Institutions are responsible for accurately reporting certain significant data elements under the Campus-Level Record that the U.S. Department of Education considers high risk, including enrollment status, which is the student’s enrollment status as of the reporting date; full-time (F), three-quarter time (Q), half-time (H), less than half-time (L), leave of absence (A), graduated (G), withdrawn (W), deceased (D), never attended (X) and record not found (Z).
Program Level: Institutions are responsible for accurately reporting certain significant data elements under the Program Level Record that the U.S. Department of Education considers high risk, including CIP Code – The Classification of Instructional Programs (“CIP”) is a set of codes that define fields of study. CIP Codes are maintained by ED's National Center for Education Statistics “(NCES”). They were most recently updated in 2020 and are usually updated every ten years.
Institutions are responsible for timely reporting, whether they report directly or via a third-party servicer. Institutions must complete and return within 15 days the Enrollment Reporting roster file placed in their Student Aid Internet Gateway (“SAIG”) (OMB No. 1845-0002) mailboxes sent by ED via NSLDS.
Condition:
The University did not submit an accurate status change notification or failed to submit timely notification to the NSLDS website for certain students who graduated, withdrew or had a change in their enrollment status (full time, half time or less than half time) during the year. Additionally, the University’s fiscal year SCHER1 report, included multiple instances in which error records were not corrected within the required timeframe.
Cause:
Insufficient internal controls and administrative oversight with respect to enrollment reporting requirements.
Effect or Potential Effect:
The University is not in compliance with enrollment reporting requirements. Failure to promptly report accurate and timely changes in enrollment status may adversely impact the repayment status for student loan borrowers.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 2 of 40 campus level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 2 of 40 campus level records tested, the University did not accurately report the students’ enrollment effective date.
• For 2 of 40 program level records tested, the University did not certify the students’ enrollment data within 60 days.
• For 13 of 40 program level records tested, the University did not accurately report one or more program enrollment data elements.
• Error records identified in Error/Acknowledgment files were not corrected within the required timeframe, resulting in multiple errors during the 2024 fiscal year.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-003.
Recommendation:
We recommend the University enhance its procedures and internal controls over enrollment reporting to ensure that significant data elements under both campus-level and program-level records are reported accurately and timely to NSLDS.
Views of Responsible Officials:
The Enrollment Reporting process is supervised by the University Registrar and is responsible for transmitting enrollment reports to Howard University’s third-party servicer, National Student Clearinghouse (NSC), who then submits the enrollment status report to NSLDS. The University Registrar resigned in July 2024 and the Associate Registrar position was also vacant at that time. These “peak time” staffing issues helped create confusion as to which enrollment files had been scheduled and sent to NSC. 1 of the 2 findings where the University did not certify the students’ enrollment data within 60 days was due to volume at NSC and deemed out of institutional control. Based on email correspondence with the Compliance Team at the National Student Clearinghouse, it was determined,
“For the delay between DV file being submitted by Howard University to NSC 08.27.2024 and processed by NSC 09.16.2024, I assess this was due to volume on NSC side at the time and outside institution control.”
The University hired an experienced Associate Director Registrar for Compliance in December 2024 and is currently searching for a University Registrar with experience working in the Workday Enterprise Resource Planning system (ERP).
Howard moved to using Workday Student as the University’s ERP beginning Fall 2024 and it has been confirmed the accurate program lengths for each program were entered in Workday. The transition to Workday Student allowed the University to review each program to ensure accuracy when integrating the data from Banner to Workday and certifying the correct program lengths are reported to NSLDS. Screenshots of the programs reported to NSLDS incorrectly have been provided to BDO as a way to document the program length will be accurately reported in the future.
Graduation files are scheduled to be transmitted on the first of every month to NSC. This will allow students cleared for graduation to be transmitted monthly and ensure the 60-day timeline will be met. In Workday, the date the student has been cleared for graduation (i.e. the effective day) is available on the “Academics” tab. This should make it easier to show an audit trail for the student’s graduation clearance date.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Federal Direct Student Loans (ALN: 84.268)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements To or On Behalf of Students – Loan Disbursement Notification - Federal regulations (34 CFR section 668.165 (a)(6)(i)) require that the institution notify the student, or parent, in writing of (1) the date and amount of the disbursement; (2) the student’s right, or parent’s right, to cancel all or a portion of that loan or loan disbursement and have the loan proceeds returned to the holder of that loan or the TEACH Grant payments returned to the U.S. Department of Education; and (3) the procedure and time by which the student or parent must notify the institution that he or she wishes to cancel the loan, TEACH Grant, or TEACH Grant disbursement. Institutions that implement an affirmative confirmation process (as described in 34 CFR section 668.165 (a)(6)(i)) must make this notification to the student or parent no earlier than 30 days before, and no later than 30 days after, crediting the student’s account at the institution with Direct Loan, FPL funds, or TEACH Grants. The Federal Student Aid Handbook further clarifies that in general, there are two types of notifications a school must provide: (1) a general notification to parent Direct PLUS borrowers and all students receiving Federal Student Aid (“FSA”) funds, and (2) a notice when FSA loan funds or TEACH Grant funds are credited to a student’s account.
Condition:
Certain loan disbursement notifications were not sent timely.
Cause:
Insufficient internal controls and administrative oversight with respect to loan disbursement notifications.
Effect or Potential Effect:
The University is not in compliance with loan disbursement notification requirements.
Questioned Costs:
None.
Context:
For 16 of 40 loan disbursements selected for testing, the notification was not sent to the borrower within the required timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures over loan disbursement notifications to ensure that such notifications are sent to students and/or parents within the required timeframe.
Views of Responsible Officials:
Howard University uses automated processes to identify and send loan disbursement notifications to parents and students. The nightly UC4 process prompted Banner to send out a Direct Loan notification to the student and/or parent. This UC4 process showed all students who had a Direct Loan disbursement after the last nightly UC4 process was run. During a compliance review of disbursement notifications during the Fall 2023 semester and the Loans Team worked with Banner consultants to determine the reason for this. While this issue was being reviewed and a solution created, the Loans Team used the RLRDLDD report in Banner, which is a report that showed all loans disbursed. This report could be matched against the UC4 listing of loans disbursed. This check between UC4 and the RLRDLDD report was used to send out loan notifications that was missed during the UC4 process during the Fall 2023 semester. During a Spring 2024 compliance review of disbursement notifications, it was discovered the RLRDLDD report was missing disbursements as well. As a corrective action, the Loans Team then began using a loan audit report out of the Argos reporting system to identify students who may have a disbursement not included in the UC4 and/or RLRDLDD report. The support time required for maintenance of Banner was also reduced due to the ongoing integration and implementation efforts to prepare Workday for the Fall 2024 semester. This increased the length of time it took to correct the UC4 process and RLRDLDD reports.
Howard no longer uses Banner to send out Graduate PLUS, Subsidized and Unsubsidized loan notifications. Workday now is now responsible for sending out the disbursement notification after a loan has disbursed and there is a record in the student’s Activity History to document the loan notification has been sent. Parent PLUS Loan notifications must be sent out manually due to Workday not having the capability to send a disbursement notification to the parent’s email on file. The “FA CR Parent PLUS Disbursement Notification Report” is run weekly out of Workday to identify all Parent Plus Loan disbursements and a notification is sent to the parent’s email address on file.
Bi-semester reviews are completed by the Associate Director for Compliance to ensure the loan disbursement notifications are being sent to students and parent in the required 30-day timeline. These reviews also ensure inclusion in the loan notification of all federally required information.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
L. Special Reporting – Fiscal Operations Report and Application to Participate (“FISAP”) - An institution is required to submit the FISAP annually by September 30, following the end of the award year, and to accurately complete all required key line items containing critical information. The deadline for submitting data corrections is December 15 of the year in which a school submits its FISAP.
Condition:
The University was unable to provide documentation to support certain data within the submitted FISAP for purposes of our testing procedures.
Cause:
Insufficient internal controls and administrative oversight with respect to FISAP reporting.
Effect or Potential Effect:
The University is not in compliance with special reporting requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation corroborating the amounts reported for tuition and fees as well as the Federal Perkins Loan Program cash on hand.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-006.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that the FISAP is completed accurately prior to submission.
Views of Responsible Officials:
Discrepancies in the area of the Perkins Loan program (Perkins) – unfortunately – are not unusual at any institution. This is due to the nature and complexity of the program being historically paper-based and required since inception to be administered and tracked by institutions. Institutions as a whole are not (have not been) adequately and equitably equipped to properly monitor decades-old and now-ended programs. To our knowledge the U.S. Department of Education (ED) did not (does not) have an issue with the response to errors provided by Howard University.
Howard University is currently liquidating the Perkins program and have assigned all outstanding Perkins loans to the ED, as well as notified borrowers their loans have been assigned to ED. The University has not originated Federal Perkins Loans since the end of the 2017-2018 award year. The majority of the fields represented in Part III Section A on the FISAP remain static and should not be changed. Educational Computer Systems, Inc. (ECSI) provides these values on the FISAP report they provide as of June 30 of each year. The only field in Part III Section A the University should tie back to the General Ledger at this time are Fields 1.1 and 1.2, which are the Cash on Hand amounts on June 30 and October 31 of each year. Parity is difficult to obtain because the vast majority of the fields in Part III Section A are static. Cash on Hand as of October 31 is calculated based on a FISAP report provided by ECSI. The report shows in Column H the change in Cash on Hand from June 30, which will be entered on the FISAP as the Cash on Hand as of October 31.
Educational Computer Systems, Inc., the University’s third-party Perkins servicer, has also stated to Howard University that mismatches on FISAP values such as Cash on Hand, Federal Capital Contribution (FCC)/ Institutional Capital Contribution. (ICC), Administrative Cost Allowance, Collection Costs and Cumulative Loan Advance and Principal Collected can frequently occur. Most ECSI clients do not attempt parity between ECSI and their ledger, so because parity is difficult to obtain, not being able to tie back data in Part III of the FISAP is not unusual. Educational Computer Systems, Inc. collaborates with schools that do not have their General Ledger match what is on the FISAP in Part III. Awareness of what data does not match and why is more important than parity.
It was discovered in December 2021 that Part III Perkins portion of the FISAP had experienced data conversion issues after the conversion from ACS Loan Servicing to ECSI as the University’s third-party servicer. There were Perkins Loans disbursed to students not included in the conversion, so the data provided annually by ECSI had accuracy issues. ECSI has stated to Howard that most institutions do not attempt to reach this parity, as it can be difficult to accomplish. Howard is liquidating the Perkins program, and assuming the University can assign all Federal Perkins Loans to ED, the Cash on Hand will then be reported as $0 in the FISAP.
The tuition and fees discrepancy on the 2526 FISAP and Financial Reporting Audit is explained by the Tuition & Fees amounts reported as of FY24 including a portion of Summer 2023 that was recognized in FY24, and a portion of Summer 2024. The charged tuition and fees amounts will not exactly agree to the financial statements due to the related GAAP deferrals and revenue recognition. Prior to the September 30, submission of the FISAP during the upcoming year, the tuition and fees will be reconciled with the tuition and fees that is reflected on the Financial Reporting audit. The tuition and fees will then be reviewed and reconciled again with the amounts reflected on the Financial Reporting Audit prior to final submission of the FISAP on December 15.
Federal Program Information:
Student Financial Assistance Cluster (Various ALN’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions – Disbursements to or on Behalf of Students - Credit Balances - An institution is required to refund credit balances on student accounts within 14 days of the creation of the credit balance. If an institution attempts to refund the credit balance by check and the check is not cashed, the institution must return the funds to ED no later than 240 days after the date the school issued the check.
Condition:
The University did not refund credit balances to certain students within the required timeframe.
Cause:
Insufficient internal control and administrative oversight with respect to the disbursement of federal awards.
Effect or Potential Effect:
The University was also not in compliance with the required federal guidelines over credit balances from student financial assistance.
Questioned Costs:
None.
Context:
For 1 of 40 credit balances selected for testing, the credit balance created by the disbursement of Title IV awards was not refunded to the student within the required 14-day timeframe.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls, policies and procedures to ensure that Title IV credit balances are paid timely to students.
Views of Responsible Officials:
There was one credit balance in the sample (from early August 2023) that was not processed within 14 days. The Title IV refund was delivered the 19th day after the credit balance was created on the student’s account. The student in question did not appear on the Bursar’s refund report until August 2, 2023. Once the student’s refund did show up, a loan adjustment was required to ensure the Bloomberg scholarship the student received did not cause an overaward. After this adjustment to prevent the overaward was made, the refund was delivered on August 8, 2023.
The Associate Director for Compliance performed five Fall 2023 and Spring 2024 reviews of 375 Title IV refunds sent to students and found zero students who had a Title IV credit balance disbursed after 14 days. Bi-semester reviews such as this are intended to catch students who may have a Title IV credit balance delivered after the 14-day timeline. In the future, there will be a sample size of one hundred students for each review and will encompass the smaller cohort of Title IV refunds sent to medical students in late July and early August. The Title IV credit balance that was not delivered within 14 days was in the Doctor of Medicine cohort who began classes a month before undergraduate students begin the Fall 2024 semester.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University’s purchasing policy and procedures are not being appropriately followed in certain cases with respect to the procurement of goods and services funded by federal awards. Certain competitive bidding documentation was not retained, and certain sole source documentation could not be provided or did not appear to give adequate reasoning for the lack of a competitive bidding process.
Cause:
Insufficient internal controls and administrative oversight over Procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with Procurement compliance requirements.
Questioned Costs:
None.
Context:
For 3 of 11 procurement transactions tested, the University was unable to provide adequate sole source justification or competitive bidding documentation.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-009.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. OPC worked with Enterprise Technology Services (ETS) to modify the Workday requisition workflow to require OPC to review all documents to ensure that procurement policies and uniform guidance are followed.
2. OPC hired three full time employees with experience with Uniform Guidance and will be responsible for processing grant related requisitions.
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
4. OPC management team will conduct intermittent audits to ensure transactions are processed according to Uniform Guidance and provide additional training to staff accordingly.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
F. Equipment and Real Property Management - Equipment property records should contain the following information about the equipment: description (including serial number or other identification number), source, who holds title, acquisition date and cost, percentage of Federal participation in the cost, location, condition, and any ultimate disposition data including, the date of disposal and sales price or method used to determine current fair market value. Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, further states that equipment owned by the Federal Government shall be identified (tagged) to indicate Federal ownership.
Condition:
Certain federally funded equipment was not appropriately tagged as required. In addition, certain property records were not properly maintained.
Cause:
Insufficient internal controls and administrative oversight with respect to Equipment and Real Property Management requirements.
Effect or Potential Effect:
The University did not comply with the requirements of Equipment and Real Property Management.
Questioned Costs:
None.
Context:
We noted the following exceptions:
• For 4 of 18 equipment items selected for testing, the University was unable to provide documentation to support that the equipment was appropriately tagged to indicate Federal ownership.
• For 2 of 18 equipment items selected for testing, property records were not appropriately updated for disposition data.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-010.
Recommendation:
We recommend the University enhance its procedures and internal controls over equipment management to ensure that federally-funded equipment is appropriately tagged/maintained and that adequate records are kept.
Views of Responsible Officials:
The Office of Procurement and Contracting (OPC) will create a Corrective Action plan to include the following.
1. Updating the following policies:
• Asset Capitalization Policy
• Sponsored Program Equipment Management Policy
2. Train all Principal Investigators (PIs), OPC staff, Sponsored Programs Office (SPO), and Grants and Contracts Accounting (GCA) personnel on all policies and equipment management protocols
3. OPC worked with Enterprise Technology Services (ETS) to require management review of all assets processed before the receipt is completed in Workday.
4. Implement an asset management platform to track assets throughout the organization.
5. Require intermittent inventory by PIs to confirm assets are available and in use.
6. In conjunction with GCA, OPC is reconciling inventory to the Workday system and ensuring all assets are appropriately tagged. On a quarterly basis, GCA forwards a report to OPC that are missing a tag number in the system. OPC must then track down each item on the list and either tag the item or update the asset in the system with the tag number."
7. OPC will collaborate with the Sponsored Programs Office (SPO), GCA, and the Controller’s Office to issue communications and provide training to all affected personnel.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (ALN: Various)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
N. Special Tests and Provisions - Publications - Per grant agreements between the University and multiple federal agencies, all publications (including conference presentations, promotional material, agendas and internet sites) that result from federal grant support by the grantors must include an acknowledgement of support and a disclaimer that the contents are the responsibility of the authors and not of the grantors.
Condition:
The University did not properly include the appropriate disclaimer of responsibility in certain publications selected for testing.
Cause:
Insufficient internal controls and administrative oversight with respect to Special Tests and Provisions requirements.
Effect or Potential Effect:
The University is not properly following its policies and procedures in place to ensure that compliance is maintained with respect to the compliance requirements associated with published information resulting from federal grant support.
Questioned Costs:
None.
Context:
For 3 of 6 publications selected for testing, the publication did not include the appropriate disclaimer of responsibility.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-011.
Recommendation:
We recommend the University enhance its procedures and internal controls over publications to ensure that acknowledgement of support and disclaimer of responsibility are included.
Views of Responsible Officials:
Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility. The University is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications.
During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. Sponsored Programs Office Pre-Award and University Compliance will be responsible for quarterly random spot checks of publications.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs/Cost Principles – Per 2 CFR Part 200.430(g)(1)(vii), budget estimates (meaning, estimates determined before the services are performed alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity performed; (B) Significant changes in the related work activity (as defined by the recipient’s or subrecipient’s written policies) are promptly identified and entered into the records. Short-term (such as one or two months) fluctuations between workload categories do not need to be considered as long as the distribution of salaries and wages is reasonable over the longer term; and (C) The recipient’s or subrecipient’s system of internal controls includes processes to perform periodic after-the-fact reviews of interim charges made to a Federal award based on budget estimates. All necessary adjustments must be made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Condition:
The University’s system of internal controls did not timely identify missing grant-related earnings allocations.
Cause:
Insufficient internal controls and administrative oversight with respect to recordkeeping of employee time and effort.
Effect or Potential Effect:
Effort certifications supporting payroll costs charged to federal awards were not completed timely or appropriately monitored during the year.
Questioned Costs:
None.
Context:
For 2 of 40 payroll charges selected for testing, allocation of the employee’s earnings was not performed timely, resulting in the delayed submission and approval of the corresponding effort certification.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-012.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure that the University is appropriately monitoring time and effort reporting.
Views of Responsible Officials:
A new office is being developed to address the timeliness of the personnel payment request forms. In Phase I, CRAs will be assigned to high-volume research colleges to provide support for costing allocations. Phase 2 will encompass existing departmental administrators who will gradually transition into more centralized research workflows supported by CRAs. A shared services model for the remaining colleges is planned for FY26.
Quarterly checklist and updates outlining cost allocation statuses will be completed with Deans and Associate Deans to determine the process needed to complete cost allocations timely.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
Research and Development Cluster (various ALN #’s)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
M. Subrecipient Monitoring - per 2 CFR Part 200.305(b), for recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means.
Condition:
The University’s procedures failed to minimize the time elapsing between the transfer of federal funds to the subrecipient and the disbursement of such funds for program purposes by the subrecipient.
Cause:
Insufficient internal controls and administrative oversight with respect to subrecipient invoice approval.
Effect or Potential Effect:
The University was not in compliance with the cash management requirements of a pass-through entity.
Questioned Costs:
None.
Context:
For 4 of 21 subrecipient invoices selected for testing, the University did not review and pay the subrecipient in a timely manner.
Identification as a Repeat Finding:
This is a repeat of prior year finding 2023-015.
Recommendation:
We recommend that the University enhance its internal controls and procedures to ensure timely review and payment of subrecipient invoices.
Views of Responsible Officials:
The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. Subrecipient invoices will be paid by Accounts Payable only after approval by SPO and GCA.
The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight.
The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO Post-Award office.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients with fiscal year ends of June 30, 2023 to submit Single Audit reports to the Federal Audit Clearinghouse within the required time frame.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
In addition, the University did not submit the June 30, 2023 Single Audit to the Federal Audit Clearinghouse by the required deadline.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Submission of the University’s fiscal year 2023 Single Audit was delayed due to the resulting investigation.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year. The related investigation also resulted in the University not submitting its 2023 Single Audit to the Federal Audit Clearinghouse within the required timeframe.
Questioned Costs:
$196,258
Context:
As discussed in Finding 2024-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2024 that identified both the suspected misappropriation and the related questioned costs.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-002.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
Accounts Payable (AP) will create a Corrective Action plan to include the following.
1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients with fiscal year ends of June 30, 2023 to submit Single Audit reports to the Federal Audit Clearinghouse within the required time frame.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
In addition, the University did not submit the June 30, 2023 Single Audit to the Federal Audit Clearinghouse by the required deadline.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Submission of the University’s fiscal year 2023 Single Audit was delayed due to the resulting investigation.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year. The related investigation also resulted in the University not submitting its 2023 Single Audit to the Federal Audit Clearinghouse within the required timeframe.
Questioned Costs:
$196,258
Context:
As discussed in Finding 2024-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2024 that identified both the suspected misappropriation and the related questioned costs.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-002.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
Accounts Payable (AP) will create a Corrective Action plan to include the following.
1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
B. Allowable Costs – In order for costs to be allowable under federal awards, they must be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E, be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-federal entity, be accorded consistent treatment, and be determined in accordance with generally accepted accounting principles.
L. Reporting - The Office of Management and Budget (“OMB”) requires recipients and subrecipients with fiscal year ends of June 30, 2023 to submit Single Audit reports to the Federal Audit Clearinghouse within the required time frame.
Condition:
Certain expenditures reported on the schedule of expenditures and federal awards were not allowable under federal guidelines, and were not appropriately approved nor supported by sufficient documentation.
In addition, the University did not submit the June 30, 2023 Single Audit to the Federal Audit Clearinghouse by the required deadline.
Cause:
Suspected misappropriation of assets arising from insufficient internal controls and administrative oversight with respect to review of federal expenditures for allowable costs. Submission of the University’s fiscal year 2023 Single Audit was delayed due to the resulting investigation.
Effect or Potential Effect:
These costs were inappropriately reimbursed with federal funds during the year. The related investigation also resulted in the University not submitting its 2023 Single Audit to the Federal Audit Clearinghouse within the required timeframe.
Questioned Costs:
$196,258
Context:
As discussed in Finding 2024-001, there was a failure with respect to the system of internal control that allowed for suspected misappropriation from specific individuals. The University performed an investigation that covered expenditures as presented on the schedule of expenditure of federal awards for the year ended June 30, 2024 that identified both the suspected misappropriation and the related questioned costs.
Identification as a Repeat Finding:
This is a repeat of prior year Finding 2023-002.
Recommendation:
We recommend the University revise its procedures and internal controls surrounding the review of expenditures charged to federal grants by defining the expectations of those that are approving the various aspects of expenditures, including clarifying expectations for reviewing supporting documentation. We also recommend that the University engage in additional training for those that are a part of the approval process for such expenditures, with the objective of renewing understanding of the procurement requirements under the Uniform Guidance as well as the expectations commensurate with their roles as approvers. Such changes will help the University ensure that expenditures are allowable based on the grant agreement and federal regulations.
Views of Responsible Officials:
Accounts Payable (AP) will create a Corrective Action plan to include the following.
1. The process to review Payment Request Forms (“PRFs”), used for payment to vendors that do not require the use of a purchase order, will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, and reasonable according to University policies and grant terms. PRFs will be reviewed by SPO and Grants and Contracts Accounting (GCA) and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards.
2. AP is working with Enterprise Technology Services (ETS) to modify the Workday Ad Hoc Business process to require additional review by PI, SPO, and GCA before payments can be issued. Each approval role will receive guidance regarding
3. AP will collaborate with SPO and GCA to issue communications and provide training to all PIs, SPO, GCA, and AP personnel.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
G. Matching - According to the grant agreement, a non-federal match of not less than 50% of the Federal funds paid by the grantor to the grant recipient under this grant is required as a condition of the grant.
Condition:
The University was unable to provide documentation showing that its cost share requirement had been met.
Cause:
Insufficient internal controls and administrative oversight with respect to cost share/matching requirements.
Effect or Potential Effect:
The University was not in compliance with the mandated matching requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation supporting that its cost share requirement had been met for the program.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and procedures to ensure that matching funds are appropriately tracked.
Views of Responsible Officials:
Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
G. Matching - According to the grant agreement, a non-federal match of not less than 50% of the Federal funds paid by the grantor to the grant recipient under this grant is required as a condition of the grant.
Condition:
The University was unable to provide documentation showing that its cost share requirement had been met.
Cause:
Insufficient internal controls and administrative oversight with respect to cost share/matching requirements.
Effect or Potential Effect:
The University was not in compliance with the mandated matching requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation supporting that its cost share requirement had been met for the program.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and procedures to ensure that matching funds are appropriately tracked.
Views of Responsible Officials:
Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements.
Federal Program Information:
University Transportation Centers Program (ALN 20.701)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
G. Matching - According to the grant agreement, a non-federal match of not less than 50% of the Federal funds paid by the grantor to the grant recipient under this grant is required as a condition of the grant.
Condition:
The University was unable to provide documentation showing that its cost share requirement had been met.
Cause:
Insufficient internal controls and administrative oversight with respect to cost share/matching requirements.
Effect or Potential Effect:
The University was not in compliance with the mandated matching requirements.
Questioned Costs:
None.
Context:
The University was unable to provide documentation supporting that its cost share requirement had been met for the program.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and procedures to ensure that matching funds are appropriately tracked.
Views of Responsible Officials:
Due to the ongoing U S Department of Transportation investigation, the awarded grants cost share is on hold. Once the investigation is concluded, Howard University will meet the cost share obligations and requirements.